1. The plaintiff's claim is dismissed.

2. The costs of lawsuit shall be borne by the Plaintiff.

1. Details of the disposition;

A. On February 3, 1989, the Plaintiff acquired and owned 1652.5/12495/124 of co-owner’s shares (hereinafter “share in the instant land”) among B forest land B 124,595 square meters (divided into C 66,678 square meters and D 55,58 square meters on September 6, 2007) in Seongdong-si, Sungnam-si, and transferred the share in the instant land to the non-party Seocho-do and the non-party E in total at KRW 300,000,000 (hereinafter “share in C”) in the transfer value of the share in the instant land at KRW 267,00,000 and KRW 33,00,000 of shares in D.

(hereinafter referred to as “transfer of this case”). B.

Upon reporting the transfer income tax on the transfer of this case, the Plaintiff reported that the transfer value is KRW 300,000,000, which is the actual transaction value, and the acquisition value is KRW 297,50,000,000, which is the conversion value.

C. On May 22, 2013, the Commissioner of the National Tax Service confirmed the purchase price of Nonparty G and H among the 10 persons who acquired shares from Nonparty F from February 1989 to March 1, 198, and notified the Defendant of the calculation and taxation of acquisition value as a transaction example. On May 22, 2013, the Defendant issued a revised and imposed capital gains tax of KRW 286,779,520 (including penalty tax of bad faith in filing a report, KRW 17,445,071, penalty tax of KRW 94,83,743, and penalty tax of bad faith in filing a report) on the Plaintiff.

On December 4, 2013, the plaintiff appealed to the Tax Tribunal, but was dismissed on the other hand.

[Ground of recognition] Facts without dispute, Gap evidence 2 and 7, Gap evidence 11-1, 2, Eul evidence 1 and 2

2. Whether the disposition is lawful;

A. (1) The Plaintiff’s assertion (1) The acquisition value for the calculation of gains on transfer under the income tax-related Acts and subordinate statutes is based on the actual transaction example, appraisal value, and conversion value in a case where the actual transaction value cannot be confirmed at the time of acquisition. Each of the above methods is stipulated on an equal and parallel basis, and there is no ground to view that the above methods are applied in sequence. Accordingly, the Plaintiff’s acquisition value of the instant land